This is a Category B project according to IFC’s 2012 Policy on Environmental and Social Sustainability due to limited E&S risks and impacts associated with the existing and planned CCI bottling plants in Türkiye, Uzbekistan, Tajikistan, and Iraq. Key E&S risks and issues for this investment are: (i) company’s capacity to assess and manage E&S risks and impacts, for capacity expansion and greenfield plants; (ii) effectiveness of CCI’s Environmental, OHS and Supply Chain policies and management systems, including CAPEX / Operational Expenditure (OPEX) for the modernization of its beverage facilities and the sourcing of its raw materials (sugar, PET, aluminum, solar panels); (iii) fair treatment and safe working conditions for its employees and contractors, including gender based violence; (iv) construction related labor/OHS policies and contractors’ management practices for brownfield/greenfield plants; (v) emergency preparedness and response during construction and operation; (vi) resource efficiency measures in line with Good International Industry Practices (GIIP) and continuous monitoring of water/energy usage and efficiency, air emissions, noise, solid/hazardous waste and wastewater; (vii) sustainable water resources management; (viii) impacts on nearby community health and safety from transport; (ix) food safety management; (x) land acquisition related to greenfield investments and right of way for water intake and discharge lines as per PS5, (xi) supply chain risk screening and management for presence of child/forced labor, significant OHS risks and significant conversion of natural habitat; and (xii) effectiveness of stakeholders’ engagement, including community grievance mechanisms.

 PS1: Assessment and Management of Environmental and Social Risks and Impacts

Environmental & Social Policies. CCI’s 2030 sustainability strategy is founded on six Environmental, Social topics covers nine sustainability commitments with specific targets related to water, packaging, climate change, diversity and inclusion, human rights and community (https://www.cci.com.tr/en/sustainability). CCI’s environmental and social (E&S) policies commit in meeting applicable national environmental and labor regulations in countries of operation. Policies’ implementation effectiveness is verified through internal / external audits, including findings and corrective actions. A global review of plant-level system performance is done annually through a management review. CCI shares its global results twice a year to CCI’s Sustainability Pledge Steering Committee. CCI adopted a corporate Environment Sustainability policy statement indicating three priority environmental areas including energy management & climate protection, water stewardship, and sustainable packaging. The policy’s scope of application covers all CCI and subsidiary employees, contractors, subcontractors, sales and distribution agencies, and third-party suppliers involved in CCI operations. The policy statement is available on the company’s website  https://cci.com.tr/portals/3/CCI_Environment_Policy.pdf. CCI will review/update its existing E&S policies including the “Coca-Cola Operating Requirements System” (KORE) guidelines to indicate its commitment to meet IFC Performance Standards (PS) requirements and World Bank Group (WBG) EHS Guidelines (ESAP#1). 

Identification of E&S Risks and Impacts. CCI integrates EHS risk assessment in its existing and proposed new operations. The scope of the EHS procedures (Standard Operating Procedures – SOPs) covers environment, technical, and OHS risks and impacts applicable to CCI employees, contractors, or sub-contractors. A risk elimination methodology is applied within the scope of its operations, warehouse activities, and quality assurance processes. CCI’s risk assessment procedures also cover systems and equipment, such as compressed gas, boilers, ammonia refrigeration systems, CO2 filling/storage, diesel storage, natural gas lines, and de(palletizer) units. CCI also developed a ‘Risk Management Procedure’ updated in 2022, and an ‘Environmental Impact Determining and Evaluating Procedure’ in 2020. The risk assessment procedures are part of CCI’s EHS management system and also integrate TCCC requirements, including workplace risk assessment and ‘Hand in Hand’ Health & Safety Program. Risk assessment policies and procedures are also aligned with the applicable national laws and regulations. All existing CCI beverage plants received the required permits and approvals from the relevant government entities in each country of operation. To assess risks associated with water supply reliability as a critical input for beverage production, TCCC developed a worldwide program – known as Source Vulnerability Assessment (SVA). The SVA studies also assess wastewater discharge vulnerabilities to community water sources (ref. PS3 section below). All CCI bottling plants are required to conduct a SVA and develop a water conservation plan (updated every five years) to mitigate water related risks.

For the new greenfield investment at Samarkand, CCI undertook an Environmental Impact Assessment (EIA) Study in line with national laws and regulations, which was officially approved by the competent authorities. For the CCI plant in Namangan, there were no risk assessments or environmental and social due diligence studies provided for the relocation of the existing plant. For CCI new facility in Baghdad, CCI undertook phase I environmental due diligence in 2019, and a recommendation was made to undertake an EIA. Going forward, CCI will submit to IFC a PS-compliant Environmental and Social Impact Assessment (ESIA) study for the relocation of the CCI Namangan plant at its new site (ESAP#2.a); CCI will submit to IFC a PS-compliant Decommissioning Plan  for the old facility in Namangan to ensure no legacy contamination or other risks are present at the plant site (ESAP#2.b). CCI will submit to IFC a PS-compliant ESIA study for the new facility in Baghdad (ESAP#2.c).

E&S Management System & Programs. In 2010, CCI adopted the “Coca-Cola Operating Requirements System” (KORE), an integrated management system designed by TCCC to integrate quality, environmental, food safety and OHS as key operational requirements. KORE supports the global quality function to perform risk determination, and to conduct regular quality, environmental, food safety, and workplace audits across all CCI plants. KORE adopts the Environmental and Occupational Safety and Health (EOSH) standards, including Global Food Safety Initiative (GFSI) requirements. It also integrates ISO management systems and standard operating procedures (SOPs) depending on type of operations (air pollution, spill prevention control, water resources management, pollution, solid/hazardous waste, and wastewater treatment). CCI also applies corporate EHS standards if more stringent than applicable national regulatory requirements. CCI plants are certified ISO 9001 (Quality Management System), ISO14001 (Environmental Management System), ISO22001 (Food Safety Management System), ISO 45001 (OHS Management System) and ISO 50001 (Energy Management System).

E&S Organizational Capacity. The Chief Corporate Affairs & Sustainability Officer is responsible for long-term target setting and the disclosure and communication of sustainability targets and performance results, and oversees the execution of climate change related strategy, action plans and disclosures. Function heads of CCI at both the Group and country levels integrate the sustainability targets set by the Sustainability Committee into their respective functional objectives. The Quality and Environment Leader at CCI is the Corporate Environmental officer and maintains oversight of different environmental coordinators in Türkiye, Iraq, Uzbekistan, and Tajikistan in charge of managing environmental issues in coordination with CCI Supply Chain Management. Each CCI facility has an environmental champion reporting to the Group supply chain environment manager. Each new bottling plant will be staffed upon commissioning, with one full-time one health & safety officer. Group Supply Chain Quality and Environment Department determines the responsibilities to monitor and report the implementation of environmental requirements and targets. The environment working group consists of country supply chain quality & environment managers and environment champions meets once every six months or after each critical environmental event. The climate, water and packaging taskforces report to the Pledge Steering Committee quarterly. Since Sustainability and Health & safety responsibilities are in different functions, sustainability related topics are discussed by the Sustainability Committee and Health & safety topics are discussed by the Health & Safety committee.

E&S Training. All CCI employees and contractors undergo a standard orientation module during recruitment. Job specific EHS training plans are developed yearly for all employees, and annual mandatory EHS trainings are undertaken in all CCI plants, sales centres, and offices. Shift start trainings are provided across all plants. CCI conducts training using its internal Health and Safety Engineers at each production facility as well as external companies for specialized OHS training (e.g. electrical safety, compressed gas and flammable liquids management).

Emergency Preparedness and Response. CCI implements the Coca-Cola Incident Management and Crisis Resolution (IMCR) program to prevent or mitigate incidents. Each CCI country of operation conducts an IMCR validation program every three years to identify gaps and improve crisis response. SOPs are developed/implemented for (i) emergency response, (ii) managing incidents/accidents, (iii) employees and visitors, (iv) third parties (contractors, sub-contractors, sales and distribution agencies), (v) risk assessment. CCI’s plants located in Industrial Zones also develop and implement the Industrial Zone Emergency Plan. CCI’s incident management teams are deployed in all countries of operation, and annual incidents trainings and simulations are undertaken. During 2022, the CCI crisis management teams from Türkiye and Uzbekistan completed their refresher trainings, and crises simulation exercises. In Iraq, Uzbekistan, and Tajikistan the Emergency Preparedness and Response procedure is available, yet it is not extended to the community. CCI will review and update the Emergency Preparedness and Response Plans (EPRP) in Iraq, Uzbekistan and Tajikistan to ensure that risks posed to nearby communities and facilities are addressed by specifying means of alerting, disclosing information and cooperating with mitigation and extinguishing measures towards the communities, industrial zone administration, and adjacent facilities in case of any emergency in CCI facilities. CCI will complete the EPRP for its greenfield Baghdad, Samarkand and Namangan facilities (ESAP#3). CCI’s emergency preparedness and response plan also includes a Fire Safety and Evacuation Plan at CCI HQ and country operations, including offices, plants, sales centers, and warehouses. In each CCI plant, drills are planned annually, as well as emergency simulations (e.g. ammonia leakage, chemical spill, fire, and security). CCI facilities in Turkey, Uzbekistan, Iraq and Tajikistan include fire detection systems and undertake annual drills. CCI plants also include a medical team, certified first aiders and in some locations ambulances for emergency medical cases.

E&S Monitoring & Reporting. CCI monitors its plants in Turkey and other countries of operation in accordance with the Environment Maturity Index (EMI) Dashboard which provides monitoring data about the environmental performance of all CCI plants. CCI also launched the ‘Hand in Hand’ Health & Safety Program to monitor EHS performance under the Safety Maturity Index (SMI) Dashboard tracked across all CCI plants and reported to the CCI Central Health & Safety team and to the Country Leadership Team. During 2022, EHS KPIs monitoring results remained compliant with local regulations and TCCC requirements. CCI also launched a digital platform “Stay Connected” to report near misses, unsafe conditions, and corrective actions. CCI plants undergo different audits for compliance, and certification, including (i) ISO 14001; (ii) TCCC KORE Audit; (iii) EME Operation Unit Audit carried out by TCCC; (iv) government audit for legal compliance; and (v) annual ISO validation audits by third party accredited organizations. All CCI facilities undergo Supplier Guiding Principles (SGP) audits of TCCC which includes labor and human rights requirements relevant to bottling operations (https://www.coca-colacompany.com/policies-and-practices/supplier-guiding-principles). Currently all CCI plants have `green` status in SGP. Uzbekistan plants are expected to undergo SGP audit in 2024 (due to recent acquisition). CCI’s ‘Integrated Report’ is the primary sustainability reporting communication tool to inform stakeholders about CCI’s ESG performance. This report includes CCI’s operations in Turkey, Iraq, Tajikistan, and Uzbekistan. Independent assurance verification is undertaken for energy, water and waste data for each CCI plant in these countries.  CCI will undertake a gap analysis of its EHS SOPs against the applicable and relevant sections of the WBG EHS Guidelines (General/Sector-specific – Food/Beverage Production) and, as needed, develop a plan to implement any relevant corrective measure identified for the seventeen plants included in this investment, and notably as it relates to: (i) noise monitoring programs and protocols to record occupational noise, (ii) contractors handling and management of hazardous waste including disposal routes for ash and quality of emissions from incinerators; and (iii) security management plans for each site in line with IFC PS4 requirements (ESAP #4.a). CCI will also undertake an independent evaluation by 2026 for a representative sample of CCI plants in each country of operation included as part of IFC existing investments. The independent evaluation will audit the following E&S topics; (i) compliance with environmental regulations; (ii) occupational health and safety (OHS); (iii) CCI E&S capacity in each country of operation and reporting lines with CCI’s Quality and Environment Leader; (iv) supply chain risks; and (v) biodiversity risks where applicable (ESAP #4.b).

Supply Chain. CCI raw material supply is classified into two broad categories (primary and secondary). The primary raw material includes concentrate, sugar, CO2 and pre-form of plastic bottles. Secondary raw material includes label, shrink and stretch (plastic package), interlayer sheet secondary packaging (paper material). Raw material is procured centrally by head office (TCCC approved / audited suppliers) from third-party suppliers certified to recognized standards (FSSC22000 – SGFA – BRC). TCCC established Supplier Guiding Principles (SGP) across all its country of operations to set out minimum requirements for third-party raw material suppliers, including compliance with applicable national laws and regulations, prohibition of child labor, forced labor, abuse of labor, promotion of freedom of association and collective bargaining, non-discrimination, wages and benefits, work hours and overtime, adoption of environmental and health and safety management practices and demonstration of compliance. CCI expects and encourages its third-party suppliers and business partners to uphold CCI Human Rights Policy principles and urges them to adopt similar policies within their own businesses. These policies are also integrated into the Supplier Code of Conduct and the contractual agreements https://www.cci.com.tr/Portals/3/Documents/PDF/Basic_Principles _for _Sup pliers_And_Business_Management_Code_of_Ethics.pdf).

No serious issues have been recorded under IFC previous CCCBPL investments based on review of compliance audit of primary suppliers / contractors /distributors. The SGP have been included in supplier agreements since 2002 for TCCC and the direct suppliers to bottlers, including CCI. Suppliers are audited by TCCC and CCI regularly and TCCC routinely utilizes independent parties to assess supplier performance according to SGP requirements. Suppliers are reviewed and evaluated annually, including on hygiene and safety. The audit results are reported to TCCC’s global audit team and tracked by CCI. Suppliers are expected to implement corrective actions to comply with the SGP requirements and to avoid agreement termination. The audits results are publicly reported in the Sustainability Report. In case of any non-compliance, CCI is committed to take necessary corrective actions and/or change suppliers. Key suppliers participate in the SGP audit program led by TCCC as explained above. CCI also started to implement the Ecovadis system for assessing the sustainability performance of their direct suppliers (currently remaining at 4-6%). Based on high-level E&S risk screening during the appraisal and previous IFC projects with CCI/CCBPL, no forced labor or child labor risks were identified for CCI suppliers. However, there is a need for introducing further traceability, risk screening and enforcement procedures to certain sectors (e.g. sugar, solar panels) where PS2 supply chain risk for CL/FL and significant OHS risks can be higher at site of production. Currently the solar panels used in the plants have been sourced from Turkey, but further risk screening and policy enforcement is needed to avoid any forced labor risks with the upcoming investments under project scope. Sugar is sourced either from local sugar refineries in the countries or imported from refineries in Brazil as raw sugar for local refineries or from Russia suppliers. This eliminates child labor risk for sugar coming from Brazil as it’s mainly harvested mechanically but in Türkiye, sugar beet remains one of the sectors with prevalent risk of child labor (according to US Department of Labor) and potentially forced labor (increased migrant workforce). CCI aims to increase the sustainable certified sugar usage in their operations. Current percentage of certified sugar in CCI total operations remain at around 10%, due to sugar import bans in their major country of operation (Turkey). CCI will develop Sustainable Procurement Policy/Supplier Code of Conduct in line with TCCC’s requirements and IFC PSs (e.g. further elaboration on elimination of child labor and forced labor risks in the supply chain, and traceability requirements, including no deforestation/habitat conversion commitments and risk screening). In collaboration with TCCC, CCI will enhance the E&S due diligence for the indirect suppliers, and also implement a verification system to ensure that its updated Supplier Code is effectively enforced with its direct and indirect suppliers (ESAP#5). 

PS2: Labor and Working Conditions

Human Resource Policy and Procedures. CCI’s key policies that govern labor and working conditions are the Human Resources (HR) Policy and associated procedures (https://cci.com.tr/Portals/3/Documents/PDF/CCI_HR_Policy.pdf) as well as the Human Rights Policy  (https://www.cci.com.tr/Portals/3/Documents/PDF/HumanRights-English.pdf). The HR policy for each subsidiary is overseen by CCI Executive Committee and includes provisions covering freedom of association and collective bargaining; prohibition of forced labour and child labour; non-discrimination; working hours and wages; safe and healthy workplace and grievance mechanism. In each country of operation, CCI’s HR policies are in compliance with national laws and regulations and consistent with IFC PS2 requirements.

Working Conditions and Terms of Employment. CCI employs a total of 9,180 employees as of 2023YE, of which 2,397 are located in Turkey, 1,494 in Uzbekistan, 805 in Iraq and 1,16 in Tajikistan. CCI has a total female employment ratio of 14%, which varies in different countries. All administrative and production workforce are under direct long-term contracts with CCI and contractors are only used for supporting services (cleaning, catering, security, etc.). During high season (summer months), temporary workers are hired under direct contracts with CCI which serves as an opportunity to build long-term skilled and trained employee base as most temporary workers transition to long-term employment. CCI offers competitive pay to workers based on sector benchmarks and provides additional premiums and benefits according to country market dynamics. Employees work 5 days a week in offices and 6 days at plants in two, 8-hour shifts and are given a break for lunch. During peak season, a third 8-hour shift is added. Overtime is practiced occasionally based on consent of workers’ and compensated at a premium rate.

Non-discrimination and Equal Opportunity. CCI Human Rights (HR) policy states zero-tolerance for discrimination, harassment, unfair treatment, or retaliation. Harassment of any kind is not tolerated in the workplace and any work-related circumstance outside the workplace. There are adequate mechanisms for reporting any misconduct and assisting employees. CCI’s sustainability strategy and HR policies target raising female employment rate as well as diversity and inclusion at the workplace. CCI put in place a robust action plan focused on increasing women in leadership roles and support female employment in non-traditional roles (e.g. forklift operator), adjusting workplace facilities (changing rooms, lactation room, standardization of maternity leave etc.), engaging with vocational schools to build a future employment base, and delivering trainings on inclusion and avoiding bias. CCI also received `Equal Pay Certificate` as first bottler in TCCC.

Workers Organization. CCI’s Human Resources and Human Rights policies recognize workers’ right to form and join organizations of their own choice. CCI’s Human Rights manager coordinates union relations at each country level as well as engagement with international sectoral union and ILO. Currently there is a sectoral workers union organized in Turkish plants (Tek-Gida) with 99% participation of workers and the negotiations for the new two-year CBA has started. In Uzbekistan, Iraq and Tajikistan currently there is no union organized in the plants. There are other engagement systems in place, such as volunteer `employee experience ambassadors, CCI women’s network and employee satisfaction surveys that provides continuous feedback from workers’ perspectives. 

Worker’s Grievance Mechanism. CCI has formalized worker grievance mechanism established in all countries of operation. This includes an independent third-party operated Ethics Line which is shared to all the workers during onboarding and announced regularly and it is open to everyone's access through the cci.com.tr website. This line with free phone access or via email provides anonymous reporting mechanism for raising any grievances directly to the Ethics Officer. Internal Audit team or Human Resources team conducts investigations with or without any appeal, engages directly with workers to assess any complaints. For the greenfield projects in Uzbekistan and Iraq, CCI will communicate the grievance mechanism for construction workers at greenfield sites (or extend corporate grievance mechanism and monitor) (ESAP#6a). 

Protecting the Workforce. CCI’s human rights policy prohibits all forms of forced labor, including prison labor, indentured labor, bonded labor, military labor, modern forms of slavery, and human trafficking. CCI prohibits hiring individuals under 18 years of age for positions in which hazardous work is required. All plants undergo Supplier Guiding Principles (SGP) audits that are organized by the TCCC and conducted by independent audit companies, which cover child labor and forced labor risks. Supply chain related risks are discussed above under PS1.

Workers Engaged by Third Parties. CCI procures third-party service providers for non-core functions. Standard contract clauses for service providers and contractors include labor laws, working conditions, provision of PPEs, and EHS requirements. CCI conducts annual performance evaluation to review compliance with contractual terms and provides EHS technical assistance to third-party service providers. Third-party contractors are issued with safety card after training/EHS induction and external supplier’s vehicles are monitored for functional seat belts. Key risk to contractor workforce is related to construction activities, especially for greenfield plants in Samarkand (Uzbekistan) and Baghdad (Iraq). At the existing CCI construction site in Samarkand, the CCI contractor provides safety checklists to sub-contractors and ‘permit-to-work’ is in place for high-risk activities as well as other life and safety procedures, and nursing staff is present at the project site during working hours for first aid. As per ESAP#6 (b), CCI will assign responsibility within their organization for ongoing review of health, safety and working conditions of the construction site workforce (c) develop a basic worker code of conduct including prevention of gender based violence and harassment and include this in the trainings of the construction workforce; (d) during peak construction period, CCI will commission independent labor and working conditions audit including OHS review for the greenfield construction sites and implement actions as necessary to ensure consistent application of national regulations and PS2 to sub-contractors.

Retrenchment: CCI workforce is in growing trend and no retrenchment is planned to take place. Regarding recent acquisition of the operations in Uzbekistan, as stated above, Namangan operations will be moved to a new modernized plant within the same city (10-15 km to city centre). CCI will prepare an employment transfer plan to avoid/minimize any redundancies, in consultation with affected workers and ensure the process is carried out in line with PS2 and local regulations (ESAP#6e).

Occupational Health & Safety. The existing OHS procedures at the corporate level are in line with IFC PS2 requirements. CCI HSE Policy is committed to implement OHS procedures for safe working conditions to all employees and contractors at its facilities. As per TCCC’ KORE requirements, CCI plants operate under current Good Manufacturing Practices (GMP) which include cleaning and sanitation, personal hygiene, pest control and housekeeping. cleaning and sanitation. CCI’s main OHS performance monitoring program is the Safety Maturity Index (SMI) dashboard tracked and reported by Health & Safety teams across all CCI plants to monitor leading and lagging KPIs and identify system implementation effectiveness and ensure compliance. CCI plant safety procedures in Turkey, Uzbekistan, Tajikistan, and Iraq consists of equipment and vehicle safety, firefighting, emergency evacuation and annual EHS trainings. CCI reported Loss-Time Injury Frequency Rate (LTIFR) of 1.5 in Iraq, 7 in Tajikistan and below 1 in Uzbekistan. The LTIFR rate in Turkey is high (37). Although this is within the country benchmark (45), it is above international benchmark (7) for the food and beverage manufacturing sector (ref. OSHA 2021). CCI will (i) conduct root-cause analysis / incident investigation training and workshops for plant OHS teams for identifying corrective actions; (ii) launch and  implement the Safe Zone project in 2024, with a dedicated working group to target adoption of site-specific safety practices in line with GIIP; (iii) replace low-visibility employee uniforms with high-visibility ones in the summer season to address accident causes;  and (iv) hire an external expert company to conduct machinery safety assessments for production lines at each plant to identify potential risks and corrective actions (ESAP#7).Currently health and safety risks for construction are managed through contractual agreements and periodic visits by country-level CCI OHS team. No significant accidents have taken place in the construction sites, including at the CCI plant in Samarkand visited during this appraisal. CCI will assign responsibility within their organization for ongoing review of health and safety of the construction site and during peak construction period. CCI will commission independent OHS audit for the greenfield construction sites and implement actions as necessary to ensure consistent application of national regulations and PS2 to sub-contractors (ref. ESAP#6(d) above).

PS3: Resource Efficiency and Pollution Prevention

Resources Efficiency. CCI’s existing plants are located in industrial zones and locations where basic infrastructure and utilities (electricity, sewerage systems, and solid waste collection) are provided by industrial estates and/or municipalities. CCI developed EHS SOPs applicable to all plants covering resources efficiency topics such as environmental management; waste management; hazardous substance; wastewater management; climate protection and air pollution control; water management; energy management (ISO 50001); and ISO 14064-1 Guidelines for Greenhouse Gases. CCI also complies with TCCC KORE requirements, which are usually more strict than applicable local laws and regulations., Periodic risk assessments as well as monitoring and audits take place at each CCI bottling plant to identify mitigation and improvement measures in relation to waste, energy, emissions, water use, and wastewater treatment and other parameters such as lighting, noise, and chemical exposure amongst others. Performance and compliance with TCCC's regulations are evaluated globally by CCI Quality Assurance Unit (ref. PS1 section). The scope of CCI’s latest independent assurance covered each CCI plant in Turkey, Iraq, Tajikistan, and Uzbekistan including water supply and water use ratio (WUR), energy consumption and energy use ratio, waste management and recycling, and GRI Standards Indicators. As part of its voluntary participation in the Climate Disclosure Project (CDP), CCI published during 2022 its water strategy and GHG data as part of CDP Water and Climate Programs.

Water Resources Use. CCI’s Sustainability Strategy entails two main commitments related to water resources including to increase water use efficiency by 20% by 2030 (2020 baseline) and to achieve water neutrality and secure water availability in water-stressed locations through community projects. At each CCI plant, water management procedures analyze supply sources and water balance, water-use efficiency, protect catchments in regions where CCI plants are located, water replenishment, and stakeholders’ engagement to mitigate any community related water risks due to CCI’s operations. The main water indicator monitored by CCI is the Water Usage Ratio (WUR) defined as the amount of water used to produce one liter of product (L/L). Based on CCI’s water saving programs between 2006 and 2018 across all operations, an improvement of 26.2% has been achieved in water use efficiency globally. During 2022, the WUR for TCCC globally was 1.81 L/L (liter of water per liter of product), and for CCI’s operations in 11 countries was 1.66 L/L, with a WUR target of 1.61 L/L in 2023. These values are below the WBG EHS Guidelines for water consumption in Food and Beverage Processing. The WUR for each CCI country of operation as part of this IFC’s proposed financing during 2022 is 1.48 L/L in Turkey, 1.93 in Uzbekistan, 2.0 in Iraq and 1.93 in Tajikistan. CCI aims to reduce WUR to 1.47 L/L by 2027, and WUR to 1.4 L/L by 2029, representing respectively 13% and 17% increase in water use efficiency (2020 baseline). To achieve this objective, CCI will continue to implement water use optimization strategies, including water recycling, wastewater treatment and effluent reuse, and will prioritize plants with higher WUR and those located in water-stressed locations. A dedicated Water Taskforce will oversee and monitor water use efficiency improvements by periodically assessing water use scenarios.  

Water Supply. Water resources supply and availability represents a material risk for CCI operations across Turkey, Tajikistan, Iraq, and Uzbekistan. Depending on the location, CCI water supply for production purposes relies on municipal water, groundwater resources, or spring/mineral sources. CCI ensures its water management practices comply with applicable national laws and regulations in each country of operation, including official government approvals and licenses for groundwater wells and other water withdrawal activities monitored by local authorities, such as State Hydraulic Works and industrial zone management. The total volume of water withdrawals is continuously measured by flowmeters, recorded daily or weekly, and reported monthly internally and externally (TCCC), and verified annually by an independent third-party auditor. To analyze water supply risks at each plant, CCI undertakes a water balance analysis through Source Vulnerability Assessment (SVA) studies and Source Water Protection (SWP) plans developed every five years to analyze (ground)water quality and quantity, volumetric monitoring of abstracted water, and quality of effluent discharge. Based on IFC’s review, the scope and quality of SVA studies reviewed during this appraisal were inconsistent and did not address corrective actions at CCI plants. CCI will (a) develop/update the Terms of Reference for the SVA studies in line with IFC PS3 requirements and WBG EHS Guidelines;  (b) assign the Group Supply Chain Environmental Manager at CCI level as well as focal points at the level of each plant to oversee the research and implementation of water investments across CCI’s plants, especially in high water stress locations; (c) develop and submit to IFC an updated Water Management Plan (WMP) for each operational plant in Türkiye, Tajikistan, Uzbekistan and Iraq in line with SVA findings for each location, including stakeholder engagement with other water users; (d) submit to IFC the SVA reports and WMPs for the new CCI plant in Samarkand, Namangan, and Baghdad; and (e) update the SVA reports for Hilla and Karbala plants and  provide the updated water licenses for CCI facility abstraction and discharge in Hilla (ESAP#8).

Wastewater and Effluent Treatment. Wastewater discharge methods at CCI operational plants include municipal sewage systems, wastewater treatment plants in industrial zones, and surface water discharge after secondary/tertiary treatment. CCI complies with local laws regulating wastewater treatment and discharge in all plants in countries of operation, as well as TCCC standards with limits for wastewater pollutants. To reduce environmental impacts, each CCI plant controls its wastewater quality parameters regularly by treatment and analysis prior to discharge. In all CCI plants, effluent water is sampled via automatic samplers and analyzed at CCI labs daily and by independent labs monthly. Spot checks are also made by the Ministry of Environment and other local water authorities. CCI’s wastewater management processes also undergo ISO 14001 audits, and third-party audits. CCI continuously develops projects to reduce the amount of discharged wastewater generated by its operations (per liter of product) in line with wastewater management target of "Zero wastewater generation and reclamation". In Turkey, wastewater is discharged to 3rd party-municipal treatment provider in five (5) CCI plants including Bursa, Elazig, Isparta, Izmir, and Sapanca. The remaining plants in Ankara, Corlu, Mersin discharge wastewater after on-site secondary treatment. Wastewater discharge in CCI Koycegiz and Hazar plants depends only on on-site pre-treatment. In Tajikistan, the CCI Dushanbe plant discharges wastewater to a 3rd party-municipal treatment provider. In Uzbekistan, all CCI plants have valid permits for water abstraction and wastewater discharge into the municipal system. The CCI Tashkent plant operates its own secondary water treatment plan (WWTP) for process wastewater where the effluent is discharged through a separate industrial sewage system. The non-industrial wastewater is discharged untreated to the municipal system. In CCI Urgench and Namangan plant, wastewater is discharged to 3rd party-municipal treatment without prior treatment. At the new CCI facility in Samarkand, construction is underway for a wastewater treatment plant (WWTP) to be completed before plant commissioning. CCI obtained government approval to discharge treated effluent into an irrigation canal using a 2km pipeline for effluent discharge, already constructed. During operation, the WWTP will meet the local irrigation requirements and TCCC water quality standards. CCI will provide the (a) update about wastewater treatment plants for all facilities in Uzbekistan, including Tashkent, Urgench, and Namangan; (b) performance specifications of the WWTP to be established in the new plant in Samarkand in line with WBG EHS Guidelines; (c) monitoring records for wastewater discharge during the construction and operational phases of the Samarkand plant (ESAP#9). In Iraq, in all three operational plants wastewater is discharged after on-site tertiary treatment. In Hilla wastewater is discharged after treatment into a surface water channel. In Karbala during 2023 the CCI plant has been connected to the municipality sewage system. In both CCI plants in Hilla and Karbala, wastewater monitoring parameters (e.g., phosphorus, ammonium, total suspended solids (TSS), COD, BOD, total nitrogen) were found in line with WBG EHS Guidelines and the corresponding indicative values for treated sanitary sewage discharges. In Erbil, wastewater is discharged in the Greater Zab River following tertiary treatment.  CCI will provide the (a) update about wastewater treatment plant for CCI Karbala in Iraq; (b) performance specifications of the WWTP to be established in CCI Baghdad plant and ensure it will comply with WBG EHS Guidelines; and (c) monitoring records for wastewater discharge during the construction and operational phases of the Baghdad plant (ESAP# 10).

Waste Management. CCI plants generate different waste categories, including glass, metals, aluminum, plastic, wood, PET, and cardboard. Waste is segregated by type and disposed of and/or recovered in accordance with local legislation and TCCC requirements. Categories of hazardous waste include caustic, Hydrochloric Acid, Sulfuric Acid, and Hydrogen Peroxide disposed of in landfills. CCI implements a zero-waste strategy across all plants, cold drink equipment maintenance centers and offices. During 2022, waste recycling rates in CCI plants reached 97% in Türkiye, 88% in Tajikistan, 96% in Iraq, and 83% in Uzbekistan. CCI also reported using 1.56% recycled plastic (r-PET) content across all CCI facilities during 2022. CCI also established collection and recycling infrastructure complying with applicable legislation in countries of operation. All CCI distributors dispatch solid waste to licensed recycling facilities. At each CCI plant, Environmental Coordinators are responsible for the implementation of waste management procedures. As part of its 2030 sustainability commitments, CCI developed packaging and waste management targets including 100% recyclable packaging and use at least 50% recycled material in plastic packaging; and collect a bottle/can for each sold by CCI in Türkiye, Pakistan, and initiate collection programs in other countries of operation. CCI created a multistakeholder Packaging Taskforce to engage with governmental and non-governmental organizations, as well as the private sector. CCI also follows the extended producer responsibility (EPR) principles for packaging waste and is a signatory to the Business Initiative for Plastics (IPG).

Storage of Hazardous Materials. In all countries of operation, CCI follows national regulations, in addition to CCI’s standards and requirements for structuring handling, storage, and transportation of hazardous materials. This includes the standardization of storage capacity, labeling, emergency response planning, and reporting processes. Hazardous chemicals are labelled according to CCI’s visual guideline. Trainings are organized on a yearly basis for all employees including hazardous chemicals handling, storage and proposal procedures. Safety Data Sheets are available at the chemical usage areas. Hazardous materials are stored in warehouses under personnel supervision, in addition to installed alarm detecting systems. Emergency Preparedness and Response Procedures include guidance on handling of hazardous material and emergency simulations for ammonia leakage (ref.  PS1 section).

Energy. CCI targets complete reliance on renewable electricity (100%) and achieving carbon-neutrality across its facilities by 2030. CCI’s long-term energy and climate action plan includes investments in energy efficiency projects, emission intensity reduction, awareness and training, and renewable energy. All CCI plants are ISO 50001 certified. CCI developed procedures for resources monitoring and conservation in its plants, including the ‘Determination of Energy Dimensions Procedure’ in 2020 to evaluate energy consumption and to develop energy programs and targets across all operations, and the ‘Energy Management Procedure’ in 2020 for energy efficiency practices. Both procedures are applicable to all CCI facilities. CCI follows Energy Efficiency Maturity Program published by TCCC which covers best practices in beverage sector. CCI plants rely on grid electricity, diesel, and natural gas for power generation. CCI targets to reduce its Energy Usage Ratio (EUR defined as energy consumed per liter of produced product) to 0.341 MJ/L by 2027, and 0.328 MJ/L by 2029 representing respectively 16% and 19% energy efficiency target (2020 baseline). CCI’s energy targets focus on three key areas; (i) production, (ii) transport and distribution, (iii) cooling practices such as HFC-free coolers equipped with Energy Management Device. Energy saving investments and action plans are separately designed for each plant and include implementing energy-efficient technologies and digitalization initiatives, such as LED lighting, electric forklifts, decreasing bottle blowing pressure, boiler efficiency, and low energy consuming equipment.

Air Emissions. CCI developed a Climate Protection and Air Pollution Control Procedure. All CCI plants are covered by an "Emission Permit" according to the Air Pollution Control Regulation and must comply with local requirements as well as TCCC limits for air emissions. The sources of stack gas emissions are boilers and heaters (natural gas and diesel), power generators (diesel), CO2 production process (natural gas and diesel), preform injection process (natural gas and diesel). Sulphur oxides (SOx), nitrogen oxides (NOx), dust and carbon monoxide (CO) parameters are measured every two years and an air emission report is prepared. As reported in CCI Integrated Report 2022, the assessment carried out has shown that air emissions from CCI plants are quantitatively and qualitatively insignificant.

Greenhouse Gases. CCI’s Sustainability Commitment aims to reduce the total absolute GHG emissions by 13% by 2030 and emissions per liter of product by 50% by 2030 (2015 baseline). CCI established a dedicated Climate Taskforce made up of representatives from various departments with the objective to reduce carbon emissions along the value chain. CCI monitors and reports greenhouse gas emissions (GHG) for each country of operation. During 2022, CCI reported the total GHG Emissions (tCO2e) for Scope 1: 98,944 (tCO2e) and Scope 2:101,149 (tCO2e) from the 17 CCI operational plants across the four countries of operation under the IFC investment. To reduce its carbon footprint, CCI supports various initiatives including; (i) Transport and Distribution “Route Optimization Project” targeting GHG emissions reduction and fuel savings; (ii) Cooling Practices including Energy Management Device (EMD) and HFC-free cold drink equipment to reduce energy consumption; (iii) Electric Forklifts; and (iv) ingredients

Performance Standard 4: Community Health, Safety & Security

Community Health and Safety. CCI developed plant-level community risk assessments, including community protection from hazardous waste/material. CCI also developed standards and company requirements for structuring handling, storage, and transportation of hazardous materials in line with country regulations. This includes the standardization of storage capacity, labeling, emergency response planning, reporting processes and such critical issues. As per ESAP#2, CCI will review and update the Emergency Preparedness and Response Plans (EPRP) in Iraq, Uzbekistan, and Tajikistan to ensure that risks posed to nearby communities and facilities are addressed by specifying means of alerting, disclosing information and providing cooperation in mitigation and extinguishing measures towards the communities, industrial zone administration, and adjacent facilities in case of any emergency in CCI facilities.

Road Traffic Safety. CCI developed a Fleet Management procedure, in addition to a ‘Contractors and Visitor Management Procedure’ in Turkey, Uzbekistan and Tajikistan. Contracts for all transporting companies include road traffic safety provisions supported and tracked by fleet department. Road traffic safety related precautions are defined and conducted by central Health & Safety teams, including KPIs for defensive driving trainings, drivers’ qualifications, and vehicle requirements. Fire extinguishers are installed in all CCI trucks and third-parties distributers. Trainings in Turkey and Uzbekistan include fleet management, drivers’ safety, and  defensive driving for company and distributor truck drivers. In Iraq, CCI implements road traffic safety through contractor management. In Tajikistan, an annual general Road safety training is delivered by a car Insurance company to vehicle drivers, but no defensive driving training is delivered. CCI will develop (a) a Fleet Management Procedure in Iraq to be implemented across the existing plants as well as the new CCI operation in Baghdad; (b) CCI will continue to monitor the effective implementation of fleet safety measures for all CCI facilities (ESAP#11).

Food Safety. All CCI plants are certified ISO22000. CCI manages food safety and product quality across its plants in line with KORE (TCCC operating requirements). The KORE requirements are based on Environmental and Occupational Safety and Health (EOSH) and Global Food Safety Initiative (GFSI) standards. CCI’s food safety targets include continuing to have no major findings in food safety and quality audits, and no product recalls were recorded. Regular KORE audits and assessments are performed at each plant by internal auditors to ensure compliance with standards and certifications. During 2022, TCCC audits included unannounced on-site, announced on-site, and virtual audits.

Security Personnel and Management Plan. For all CCI plants, a Security Instructions Manual is integrated into CCI’s management system covering all production plants in different locations. An annual security risk assessment process is conducted individually for each CCI plant. Security is unarmed at all locations under the scope of investment. Security contractors must abide by CCI’s Human Rights Policies and adequate reporting channels are in place in case of any misconduct.

PS5 – Land Acquisition and Involuntary Resettlement

TCCC has a Responsible Land Acquisition Guidance. SGP audits also cover review of land rights of affected communities from third-party suppliers. CCI’s Human Rights Policy recognizes the importance of land rights (including customary, if applicable) and community resources. CCI prioritizes to locate their plants in land plots within established industrial zones. If industrial zone land is not available, then CCI assess other available land whereby CCI’s Land Acquisition Procedure is followed including a legal due-diligence stage and acquisition of land through willing buyer-willing seller arrangements based on independent assets valuation. The procedure does not include review and mitigation of social impacts (survey of users and vulnerable groups dependent on land, security of tenure, livelihood impacts etc.). For the water sourcing and discharge lines, CCI follows avoidance strategy and seeks to install pipelines away from community assets. CCI will (i) update their land acquisition procedure to include requirements in line with IFC PS5; (ii) establish clear procedures for the assessment and mitigation of right of way impacts of water intake and discharge lines as per PS5 (ESAP#12). There are two greenfield investments as part of the project. One of them is under construction in Samarkand within the Urgut Free Economic Zone (on approximately 180,000 m2 of land acquired from the government on 49 years of lease). The construction of the other CCI greenfield in Baghdad is scheduled to start in 2024. Land acquisition for Baghdad has been completed in 2023 for 100,000 m2 of land from residential/agricultural users and converted to industrial land.  CCI will also decommission and relocate its Namangan plant to the IBRAT Special Economic Zone, expected to become operational in 2025. The plant’s land was acquired for 28 years lease period in October 2023 through a government auction process. Other plant expansions included in the project scope will not require additional land acquisition. The existing and new plants have not required any expropriation and not expected to do so in future. As part of ESAP #12 (iii) CCI will engage a third party consultant to review past land acquisition process for CCI Baghdad plant to identify affected past users to the extent possible, engage with affected community members to identify any ongoing grievances related to use of land and community resources and develop a social assistance plan if the review identifies vulnerable people who were not able to reestablish their living conditions and livelihoods after land acquisition.

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

A total of 17 operational bottling plants and two greenfield developments were assessed to identify risks and impacts to biodiversity values and ecosystem services, as well as to define PS6 supply-chain requirements for CCI’s purchase of sugar to be used as a raw material in its operations. Of the existing CCI facilities, four in Turkey (Corlu, Ankara, Isparta and Mersin), one in Iraq (Karbala), one in Tajikistan (Dushanbe), and one of the greenfield developments in Uzbekistan (Samarkand), are all located in converted habitat with no identified overlap with Legally Protected Areas (LPAs), Internationally Recognized Areas (IRAs) or priority biodiversity values. Therefore, biodiversity-related risks associated with these facilities are considered insignificant. In five of the plants in Turkey (Koycegiz, Bursa, Sapanca, Hazar and Elazig), and one in Iraq (Hilla), there are potential risks associated with water withdrawal from basins close to each of the facility. As indicated in ESAP#8, an updated Water Management Plan will be developed and implemented for each plant in line with IFC PS1 and PS3. For two facilities in Iraq (existing one in Erbil and the planned plant in Baghdad), there are risks related to wastewater discharge into the Greater Zab River and Tigris River, respectively. In line with ESAP#10, wastewater monitoring will be updated for Erbil and performance specifications will be defined for the new facility in Baghdad. Two CCI facilities in Turkey (Koycegiz and Izmir) are located in the Koycegiz Lake Key Biodiversity Area (KBA) and the Nif Mountain KBA, respectively. The first in Koycegiz includes rooftop PV installations at the existing facility with no footprint expansion. Therefore, impacts on biodiversity values associated with the KBA/IBA are not anticipated. Regarding the second one in Izmir, there is no overlap of the client’s facilities with the relevant biodiversity values associated with the Nif Mountain KBA which are endemic plant species that occur at elevations higher than 1,500 m asl. Nonetheless, as per ESAP#13, CCI will consult with relevant stakeholders with respect to their activities in Koycegiz Lake and Nif Mountain Key Biodiversity Areas (KBAs) and identify any risks that should be considered.

Sustainable Management of Living Natural Resources

CCI purchases sugar as a raw material for its beverage operations. Currently, sugar used in existing facilities in Turkey and Iraq is sourced from domestic producers, while in Tajikistan it is supplied from Russia and in Uzbekistan refined sugar is supplied from domestic producers while domestic producers procure raw sugar from Brazil, where it may be associated with natural habitat loss. As mentioned in PS1 section, to supply its global operations, CCI has committed to importing 10% certified sugar from Brazil, although it is not clear if this regards Bonsucro certification (or another credible production standard) that would include no deforestation/habitat conversion requirements. In line with their Principles for Sustainable Agriculture (PSA)TCCC’s target is to source all its sugar supply sustainably. PSA defines principles to avoid deforestation and natural habitat conversion and identifies global sustainability standards and certifications approved by the company (i.e. Bonsucro, SAI Farm Sustainability Assessment). TCCC maps and verifies its sugar suppliers against a company-approved, third-party validation that is aligned with PSA. As per ESAP#14, CCI will comply with TCCC’s PSA in seeking opportunities to gradually increase the 10% of certified sugar and shift to purchasing sugar directly from their existing suppliers that are verified to TCCC-approved sustainability standards or directly from producers who provide certified sugar (i.e. Bonsucro), where there is a risk of deforestation/habitat conversion in areas of production.

  CCI’s community relations and stakeholder engagement is led by the Public Affairs and Communications team. Since 2013, CCI conducts comprehensive stakeholder mapping based on AccountAbility's AA1000 SES Standard and the European Foundation for Quality Management (EFQM) Company Excellence Model to prioritize stakeholders and improve communication channels at corporate and national level in respective countries. CCI also established different Communication Platforms with both its internal and external stakeholder groups including employees, suppliers, distributors, customers, consumers, public institutions and organizations, unions, NGOs, media, sector groups. CCI holds periodic stakeholder engagement activities country specific interventions. CCI discloses key updates related to their operations and E&S impacts within Annual Integrated Reports https://integrated.cci.com.tr/home.

CCI dedicates different  communication channels for grievances or inquiries  such as the independent third party operated Ethics Line (https://www.remedetikhat.com.tr/en),  Coca-Cola Call Centre, CCI'm Curious Platform, Coca-Cola Social Interaction Centre, website and social media channels, informative publications and plant visits by stakeholders (on demand). CCI also has separate engagement channels with farmers and communities as part of the CSR program that targets waste management, water replenishment and women’s employment. CCI periodically engages with NGO and governmental partners to assess the needs of project stakeholders. For the CCI production plants that are located outside industrial zones and where there’s an affected community, preparation of a site-specific Stakeholder Engagement Plan is required under PS1. CCI will identify the existing and greenfield plant locations within the project scope where there’s a nearby affected community, develop site-specific Stakeholder Engagement Plans (SEP) meeting requirements of PS1 and disclose grievance channels in an accessible format to affected communities. CCI will include the requirement related to preparation of site-specific SEP, within the corporate level stakeholder engagement procedures (ESAP#15).

  The ESRS will be made available via IFC Project Information Portal and at CCI in Turkey and other countries of operation.